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I have reviewed Method 5210B (BOD/CBOD) in the 22nd Edition of Standard Methods and found on one substantial change. The attached Word document identifies the change, and documents my thoughts on the change.File Attachment(s):MS-MSDRequirement.doc(28160 bytes)

I did check out the table in the 22nd edition and I noticed that by Method 5210B, there were not any "x" to indicate the LFB and LFMD was required for this method and in the footnote, it stated that QC requirement stated in method.

That was my interpretation, a regulator may have a completely different approach.

You are correct, Suzy, in stating there is not an "x" in the LFB and LFM/LFMD columns, but the next column lists footnotes 1, 2, and 3 as requirements. Those footnotes are for LFB, LFM, and LFMD, respectively!. Go figure!. So which is right...the column that says they aren't required, or the column that says they are? We all know that a lab fortified blank (LFM) has been required forever...it's the GGA standard, of if you like the fancy new terms, the GGA LFB. So I choose to believe they are saying Footnotes 1, 2, and 3 are required. At best, the table is very confusing! In your other posting you mention an "LCS/LCSD standard". What is that? "LCS Standard" could mean "Lab Control Standard", but that (I assume) is the GGA solution, which they call the LFB. If so, what does that have to do with the "effluent" you mention in the same sentence?

Sorry, yes LCS/LCSD is the same thing as a lab fortifified blank. The effluent comment was addressing the LFM approach, I was trying to state that you could run a GGA in an effluent sample, since it should have very low concentration of BOD.

I didn't get that far to the footnotes, but I will have to take a look.

On another note, I think the reason for this is based on the Federal Register's final ruling today established 12 essential QC items for every test method, even if the test method doesn't specify any QC.

This is a strange situation since EPA posted a statement that the 22nd edition of SM was merely an "editorial" update of the actual approved method. This would indicate that the BOD method is not.

From a legal standpoint the approved method is the one freferenced in the federal regulations and is the one approved byt the JTG in 2001. Any copy of that is relavent. Also note that EPA killed the 12 Elements as requirements for QC and relegated them to option number 3 in cases where a method lacks QC (Note that it is not when a method lacks adequate or sufficient QC, but totally lacks QC).